FCA US LLC
Effective Date: September 30, 2016
Welcome to FCA US LLC ("FCA US"). At FCA US, we believe it is important to protect the privacy of our customers and guests and to be transparent with our practices. We know that you care about how your personal information is collected, used, and shared and we want to help you make knowledgeable choices about the information you provide to us. This Privacy Statement ("Privacy Statement") explains and summarizes how FCA US collects, uses, and protects your information, including the personal information that you may provide to us or that we may collect from you as you interact with us. We will update this Privacy Statement from time to time, so please check back with us periodically.
This Privacy Statement explains the information practices of FCA US including:
FCA US collects and uses the information you provide to us. We may also obtain information about you from outside sources. For example, we may obtain commercially available demographic information about you from third parties, get device identifier information from mobile applications or advertisements or purchase e-mail or similar lists from third parties for advertising and marketing purposes. We may use or share your Personal Information where it is necessary for us to complete a transaction or do something that you have asked us to do, like to "get a quote" or to "find a dealer" or to send you products or vehicle information. We may also use this information for our internal research purposes as we develop our products and services. We may use Personal Information and data collected for our advertising or marketing purposes including on other websites or media and we may communicate with you to provide you with information we think may be of interest to you.
If you make a request for information, for example, we might need to provide your name, address, or email to one of our dealers or a service provider with whom we have a relationship so that they can help us respond to you. FCA US vendors and suppliers may process your personal data under the direction of FCA US and in accordance with our policies.
We collect and use information from you in certain ways including:
Website or Application Usage. We (or our service providers) may observe your activities, preferences, and transactional data (such as your Internet Protocol (IP) address and browser type) as well as pages you have viewed during your use of our Website or Application. We may use this data for any purpose unless we tell you otherwise in connection with a particular Website or Application. While we may collect or log this information, we do not identify you except if we believe doing so will help us better respond to a request you have made such as for a quote, identification of a local dealer, or similar request. With the exception of Location-Data, described below, where such non-Personal Information is linked to your Personal Information we will treat such information as Personal Information.
Location Data. Some FCA US Websites or Applications may capture and record certain location-data regarding your use of that Website or Application and your travels in order to provide location-related functionality ("Location Data"). We may link that Location Data to other information that you provide to us or that may be accessed in connection with your use of such a FCA US Website or Application. Your use of, and our ability to offer location based functionality is then enabled through our use and disclosure to third parties of Location Data and associated information.
E-Commerce. When you interact with us or purchase a FCA US product online (for example, to get a quote or locate a dealer) you will be asked for information needed to complete your request. The information you provide is used, for example, to process your transactions, to create and share reports about these transactions, or to provide related customer service. When you shop online or buy direct from one of our online stores, these purchase transactions may be conducted through FCA US vendors and suppliers. Vendors and suppliers engaged by FCA US may have their use of your Personal Information limited by this Privacy Statement, contractual restrictions, or applicable law. However, if a particular Website or Application is co-branded or developed by a third party, it is possible that another party's Privacy Statement will govern the treatment of information on that Website or Application. FCA US (through its vendors or suppliers) may limit the acceptance of orders to particular jurisdictions and as permitted by applicable law.
Product Registration and Support. FCA US may allow customers to register online. Personal Information provided for such purposes may be used to carry out the request, service, or agreement for which the information is submitted. With your consent, we may also use the information you provide in online registration forms to notify you periodically about important things like an update to the Application, a change to our Privacy Statement or notice of a security breach, new FCA US products and services, and special offers and promotions that may be of interest to you. Failure to register any FCA US product will not diminish the rights you have under the applicable product warranty.
Events and Promotions. You may be asked to provide an email address or other Personal Information at an event or for entry into a particular promotion (including sweepstakes and contests). The specific rules and regulations governing promotions will vary and your participation constitutes your agreement to abide by those rules and regulations.
Certain promotions may be run by a FCA US service provider or vendor or be co-branded with one of our partners or run on a third party site like Facebook. In these instances the collection of your Personal Information may occur directly by the service provider or vendor or by a third-party partner on their website. The promotion will state the policies governing the collection of such information if they should differ from this Privacy Statement.
You may opt out or control how your information is used by sending an email to firstname.lastname@example.org.
DAA Principles for Behavioral Advertising. FCA US participates in the industry Self-Regulatory Program for Online Behavioral Advertising managed by the Digital Advertising Alliance (DAA)(www.aboutads.info). As part of this service, FCA US online advertisements are sometimes delivered with icons that help consumers understand how data about them is being used and provide choice options for consumers that want more control and an ability to opt out of such behavioral (targeted) advertising. FCA US (and/or our partners) may use data collected on our websites to customize advertisements to you on other sites as you browse the web. Please click on the DAA icon or the icon in our targeted advertisements to opt out if you do not want your browsing behavior used for online behavioral advertising purposes.
Children. FCA US Websites or Applications are not directed at children. If you are under 18 or otherwise would be required to have parent or guardian consent to share information with FCA US, you should not send any information about yourself to us. If a person under 13 submits information through any part of a FCA US Website or Application, and we learn the person submitting the information is a child, we will attempt to delete this information as soon as possible. Because we do not knowingly collect any Personal Information from persons under 13, we do not use or disclose such information to third parties.
FCA US may share your Personal Information within our enterprise to fulfill our obligations to you and operate our business consistent with this Privacy Statement and applicable data protection law. We may also share your Personal Information with third parties in certain situations, including:
FCA US Affiliates, Vendors and Suppliers. "Affiliates" include FCA US dealers, companies that are part of the FCA US LLC family of companies, , FCA US partners or their respective subsidiaries, employees, and supplemental workers. Vendors and suppliers are companies who perform services for FCA US or its dealers. To the extent it is necessary for these groups to provide their products and services to us and provide products and services you have requested, these third parties may have access to or process your Personal Information. FCA US may sometimes permit our authorized service providers to have access to aggregate statistics about our customers, sales, traffic patterns, and related Website or Application information. These transfers of aggregate statistics do not involve Personal Information.
Recruitment and Job Applications. Personal information such as that contained on a resume or curriculum vitae may be submitted in connection with a job application or inquiry. We may use this information throughout FCA US (worldwide) for the purpose of employment consideration or your inquiry. We may keep your information on file for future consideration.
Enabling Services. FCA US offers a variety of services and functions through its Websites and Applications. Personal Information that is collected through a Website or Application may be used and/or disclosed to third parties in order to enable us to provide functionality or services to you. For example, some FCA US Websites and Applications allow you to interface with third party websites or applications. To facilitate that connection, we may use your Personal Information and/or disclose your Personal Information to third parties. When we provide location based services enabled through a third party, we may share data with those services in order to provide the related location based service or functionality.
Public Areas. Any information disclosed in public areas of a FCA US Website or Application or third party website (for example, through Facebook, YouTube, Twitter or other sites) will become public information. We cannot control the use of information disclosed in public forums, such as social media platforms, blogs, forums, wikis, chat rooms, and networking functions of mobile-device applications. You should exercise caution when disclosing information in these public areas, especially your Location Data, and be careful how you disclose your Personal Information. Content posted in public areas of FCA US Websites or Applications, including advice and opinions, represent the views and is the responsibility of those who post the content. FCA US may not endorse, support, verify, or agree with the content posted. If you have any questions or comments about any content on a FCA US Website or Application please send an email to:email@example.com.
Mergers, Acquisitions, and Insolvency. If FCA US should ever file for bankruptcy or merge with another company, or if FCA US should decide to buy, sell, or reorganize some part or all of its business, FCA US may be required to disclose your Personal Information, including to prospective or actual purchasers in connection with one of these transactions.
As Required by Law and Other Extraordinary Disclosures. FCA US may be required to disclose your Personal Information if it: (i) believes it is reasonably necessary to comply with legal process (such as a court order, subpoena, search warrant, etc.) or other legal requirements of any governmental authority, (ii) would potentially mitigate our liability in an actual or potential lawsuit or investigation, (iii) is otherwise necessary to protect our rights or property, or (iv) is necessary to protect the legal rights or property of others.
Data transmissions over the Internet cannot be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk. Once we receive your information we make reasonable efforts to ensure security on our systems. FCA US uses secure server software (e.g. SSL) and firewalls to protect your information from unauthorized access, disclosure, alteration, or destruction. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of such firewalls and secure server software.
If FCA US learns of a security system's breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By providing Personal Information to us or using this Website or Application, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues. FCA US may post a notice on our Website or through an Application if a security breach occurs. If this happens, you can view the notice on a FCA US Website or Application. FCA US may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice) you should send an email to firstname.lastname@example.org.
You may restrict FCA US use of your personal data for direct marketing purposes. You may also request access to, correction of, or deletion of personal data for this purpose. For instructions on changing any of your privacy preferences, accessing your information, updating your information or for any privacy or data-protection-related question please send an email to email@example.com for assistance.
Because FCA US operates globally, we may transfer your Personal Information within our global operations to fulfill our obligations to you, but always subject to the limitations of applicable data protection law and this Privacy Statement. Privacy laws differ across the globe. To help visitors whose native language may not be English understand our privacy practices, we may provide special information that may be applicable to these visitors in different languages. FCA US entities outside the United States may have supplemental privacy policies that apply in those countries.
If you are visiting from Canada, the European Union (EU) or other regions with laws governing data collection and use that may differ from United States (U.S.) law, including those whose privacy laws may be more stringent than U.S. law, please note that you are transferring your personal data to FCA US in the United States. By providing your personal data you consent to that transfer.
FCA US complies with the EU-U.S. Privacy Shield and U.S.-Swiss Safe Harbor Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from EU member countries to the United States. FCA US has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. The definitions, policies, and procedures described in this Privacy Statement apply to personal data transferred pursuant to Privacy Shield certification by FCA US. This section describes how FCA US complies with the specific Privacy Shield principles not covered in other sections of this policy. If there is any conflict between the policies covered in this Privacy Statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.
Data Collection and Use: Privacy Shield Personal Data includes Personal Information data that is collected from consumers, our workforce, vendors, suppliers and others in connection with the manufacture, distribution and sale of automobiles and related goods and services in the EU/ European Economic Area (EEA) and/or Switzerland. This data covered includes manually processed information: location, recruitment and job applications, website or application usage, product registration and support, and other human resource information.
In addition, Privacy Shield Human Resources Personal Data is collected from potential and hired employees and is used for internal purposes, including system access, payroll and benefits, training, security, reporting, and global corporate directories. Sensitive Information (e.g., information about medical condition, race or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or information specifying the sex life of the individual) may be collected for HR purposes in relation to individuals in the EU.
Notice and Consent: To the extent that FCA US collects personal data directly from individuals in the EU, and as provided under the Privacy Shield, FCA US will provide those individuals with notice and a clear, conspicuous, and readily available mechanism for requesting that their personal data not be used for specific purposes or disclosed to certain third parties. FCA US will obtain affirmative express consent for the disclosure of any sensitive information to a third party or if used for a purpose other than those for which it was originally collected or subsequently authorized.
To the extent that FCA US acts solely as a data processor when processing personal data on behalf of data controllers, FCA US acts only on the instructions of its controller and does not control or share such personal data without direction from the controller. In those instances, and to the extent provided for by applicable law, FCA US may rely on its data controller to satisfy the notice and consent principles under EU and EU Member State law, and will act on the instructions of those controllers.
Access: EU Data Subjects have the right to access personal data about them that is covered by this Privacy Shield Policy. Personal data can be corrected, amended, or deleted by EU Data Subjects, subject to certain limitations permitted by the Principles.
Onward Transfer: FCA US may share EU personal information with the types of third parties indicated above and in a manner that is consistent with our Privacy Statement and the Privacy Shield Principles. FCA US will maintain written contracts with those third parties to whom it discloses Personal Data, and will require those third parties to:
FCA US also requires that the recipient will provide the same level of protection as the Privacy Shield Principles and that the recipient will notify FCA US if it makes a determination that it can no longer meet those obligations.
To the extent provided by the Privacy Shield principles, FCA US remains responsible and liable under the Privacy Shield if the third-party agents that it engages processes the personal information on its behalf in a manner inconsistent with the Privacy Shield principles, unless FCA US is able to prove that is not responsible for the event giving rise to the damage.
Recourse, Enforcement and Liability: In compliance with the Privacy Shield Principles, FCA US commits to investigate and will attempt to resolve complaints about your privacy and the collection or use of your personal information within 45 days. European Union citizens with inquiries or complaints regarding this Privacy Statement should first contact our Data Protection Office by sending an email to firstname.lastname@example.org.
FCA US commits to cooperate with the panel established by the European Union Data Protection Authorities (DPAs) and comply with the advice given by the panel with regard to data transferred from the EU. Pursuant to the Privacy Shield Principles, if you do not receive timely acknowledgement of your complaint or if your complaint is not satisfactorily addressed, please contact the DPA at http://ec.europa.eu/justice/data-protection/bodies/index_en.htm
If your dispute remains fully or partially unresolved after taking the above actions, under certain and limited conditions, you may invoke last resort binding arbitration by a "Privacy Shield Panel" composed of arbitrators designated by the U.S. Department of Commerce and the European Commission. An individual's decision to invoke this binding arbitration option is entirely voluntary.
It should be noted that FCA US is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).
In the future we may change our Privacy Statement and we will post the new Privacy Statement on our Websites or Applications. Your continued use of this Website or Application following a change in the Privacy Statement represents consent to the new Privacy Statement to the fullest extent permitted by law. We encourage you to periodically review this Privacy Statement.
FCA US LLC
Attn: Data Protection Office
1000 Chrysler Drive
Auburn Hills, MI 48326